amount varies depending upon the size of taxpayer or transaction and whether the matter is an initial APA matter or renewal

Tax collection / penalty / interest

- collection: other than in exceptional cases, there should be no collection proceedings regarding a proposed adjustment (or related interest or penalties) that is the subject of MAP

- interest: on reciprocal basis, the US will agree to waive interest due on amounts repatriated to implement a MAP agreement

* The US has not agreed to negotiate the amount of penalties or interest due on deficiencies and refunds during MAP.

Other dispute resolution mechanisms

- Arbitration procedure under bilateral income tax convention

* Income tax treaty with Germany is the only US treaty with a currently effective arbitration provision. Several other treaties with arbitration provisions the US has entered into will not take effect until exchange of notes.